We supply digital backpacks to the city's delivery and cycling network and use these backpacks to provide businesses with an outdoor advertising platform (Services). LUMOS Technology ABN 93 638 135 636 (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our Services or when otherwise interacting with you.

1. The information we collect

   Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable. The types of personal information we may collect about you include:

   1. As a business contact for a customer of ours: your name; your contact details, including your work email address and/or telephone number; and the organisation you work for.

   2. As one of our riders (or prospective riders): your name; your contact details, including your email address, address and telephone number; your date of birth; geolocation data from the backpack we supply you with and you wear; and identification documents that you provide to us to verify your identity, such as your driver licence or passport.

   3. When you visit our website or otherwise contact us: if you submit an enquiry to us, your name and contact details; information you provide to us, including through feedback, customer surveys or otherwise; your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour; information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider; additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and any other personal information requested by us and/or provided by you or a third party.

   4. Sensitive information: is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. If you sign up with us to be a rider, we may request information to verify your identity such as your driver licence or passport. This information may include sensitive information, including that where we collect your photo identification documents, we may see sensitive information about you such as your organ donation preference and information that may infer your ethnicity or religious beliefs. Unless otherwise permitted by law, we will not collect sensitive information about you without first obtaining your consent.

2. How we collect personal information

   We collect personal information in a variety of ways, including:

   1. Directly: We collect personal information which you directly provide to us, including when you sign up as a rider, through the ‘contact us’ form on our website, when your business signs up for our Services and you are the business contact or when you request our assistance via email, or over the telephone.

   2. Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries, and where you are a rider, through the location of your backpack.

   3. From third parties: We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.

3. Why we collect, hold, use and disclose personal information

   Personal information: We may collect, hold, use and disclose personal information for the following purposes:

   1. As a business contact for a customer of ours: to contact and communicate with you about our Services, including in response to enquiries you make with us; for internal record keeping, administrative, invoicing and billing purposes; for analytics, market research and business development, including to operate and improve our Services, associated applications; for advertising and marketing, including to send you promotional information about our services and other information that we consider may be of interest to you; to comply with our legal obligations and resolve any disputes that we may have; and/or if otherwise required or authorised by law.

   2. As one of our riders: to assess your application to become a rider; to contact and communicate with you about our Services; for internal record keeping, administrative, invoicing and billing purposes; to track your location for the purpose of analytics (including to provide anonymised data and metrics to our customers), market research and business development; to comply with our legal obligations and resolve any disputes that we may have; and/or if otherwise required or authorised by law.

   3. When you visit our website or otherwise contact us: to provide our website to you; to contact and communicate with you about any enquiries you make with us via our website; to comply with our legal obligations and resolve any disputes that we may have; and/or if otherwise required or authorised by law.

   4. Sensitive information: We only collect, hold, use and disclose sensitive information for the following purposes: any purposes you consent to; the primary purpose for which it is collected, including to verify your identity if you would like to become one of our riders; secondary purposes that are directly related to the primary purpose for which it was collected, including disclosure to the below listed third parties as reasonably necessary to provide our Services to you; to contact emergency services, or to speak with your family, partner or support person where we reasonably believe there is a serious risk to the life, health or safety of you or another person and it is impracticable for us to obtain your consent; and if otherwise required or authorised by law.

4. Our disclosures of personal information to third parties

   1. We may disclose personal information to: third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) IT service providers, data storage, web-hosting and server providers such as Google, email marketing providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators; our employees, contractors, and/or related entities; our existing or potential agents or business partners; anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred; courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you; courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses; and any other third parties as required or permitted by law, such as where we receive a subpoena.

   2. Google Analytics: We have enabled Google Analytics Advertising Features including [Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting etc.]. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

5. Overseas disclosure

   While we store personal information in Australia, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia.

6. Your rights and controlling your personal information

   1. Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to engage you as a rider, to provide our Services to you and your use of our Services.

   2. Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

   3. Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

   4. Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

   5. Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

   6. Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

   7. Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner.

7. Storage and security

   We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

8. Cookies

   We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

   You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website

9. Links to other websites

   Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

10. Use of geo-localisation data from our riders

    Where you are a rider, we collect precise or approximate location data via the backpack we provide to you for the following purposes: to generate analytics for, and provide feedback to, our customers that are advertising on your backpack; to monitor when the backpacks are in use; to track where our backpacks are; and as permitted by law.

    We collect this information when your backpack is turned on. If you do not wish to provide such location information to us, we may not be able to engage you as one of our riders.

11. Amendments

    We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact us at:
LUMOS Technology
ABN 93 638 135 636
Email: info@spotlumos.com
Last update: 5 January 2022 © LegalVision ILP Pty Ltd

Privacy Collection Notice

Updated January 2022

This Privacy Collection Notice describes how Leggo Studio Pty Ltd ABN 93 638 135 636 (we, us or our) collect and handle your personal information when you [submit a request for a quote with us / apply to be a rider with us / make an enquiry with us]. We collect personal information from you so that we can [provide you with a quote / assess your application / verify your identity / provide our marketing services to you / respond to your enquiry] and for related purposes set out in our Privacy Policy, available at https://spotlumos.com/privacy.

We may disclose this personal information to third parties, including IT service providers, data storage, web-hosting and server providers such as Google and as otherwise set out in our Privacy Policy (linked above).

While we store personal information in Australia, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia.

If you do not provide your personal information to us, it may affect our ability to provide our Services to you and your use of our Services. Please see our Privacy Policy (linked above) for more information about how we collect, store, use and disclose your personal information, including details about overseas disclosure, access, correction, how you can make a privacy-related complaint and our complaint-handling process.

If you have questions about our privacy practices, please contact us by email at: info@spotlumos.com . By providing your personal information to us, you agree to the collection, use, storage and disclosure of that information as described in this privacy collection notice.